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Some NGOs Able to Continue Longer-Term Temporary Activities for a Second Year

One key question many foreign NGOs continue to ask is whether they will be able to reliably use temporary activities to carry out multi-year or other types of long-term programs or grants in China. As any given temporary activity may not last more than one year (except in cases “where there is a need” and permission is explicitly granted), and Chinese authorities have not offered any official guidance on the subject, it remains unclear how dependable the temporary activity mechanism is for groups that plan to fund longer-term projects but do not wish to open a representative office in China.

The China NGO Project wrote last August that at that time around 10 organizations appeared to have used the temporary activity mechanism to carry out a program that was substantively the same as a previous one—that is, in the same location, with the same CPU. (For the purposes of this analysis, we will refer to this process as “renewal,” even though there is no formal renewal process specified in the law.) Since then, substantially more groups appear to have successfully “renewed” temporary activities—using a loose set of counting criteria described below, around 90 activities in all.

These “renewed” activities only account for a minority of total temporary activity filings (about 13 percent of the 1,417 filings in the data reviewed for this analysis), but the fact that there are now nearly 100 of them suggests that, for some groups at least, temporary activities may indeed be a durable method for administering multi-year programs and grants. As always, our data, sourced from the Ministry of Public Security (MPS) website, only shows us successful filings; we do not know if or how many groups sought to “renew” a temporary activity and were unable to do so. Our estimated numbers here should not be taken as hard and fast—as we discuss below, we likely did not identify all of the “renewals,” and we may have counted an activity as a “renewal” that might better be classified as an “extension.” However, our figures can still be useful as ballpark estimates with which to get a sense of how some foreign NGOs are using the temporary activity mechanism for longer-term projects.

Our data cutoff date for this analysis was January 31, 2019. To arrive at a rough estimate of 90 “renewals,” we identified organizations that had more than one activity with exactly the same or a very similar name, that was carried out in the same location, and that was done so in conjunction with the same Chinese Partner Unit (CPU). As this analysis aims to assess whether longer-term projects are possible under the temporary activity mechanism—rather than gauging the success of short annual events such as conferences—we only included activities in which one of the filings, usually the second one, was at least six months in length. The other filing needed only to have been at least two months in length, as it appears fairly common for an NGO to file a first activity as something of a “test” or proof of concept, and later file a longer version of the same activity. We included pairs of activities even if there was a gap between the end of the first activity and the start of the second activity—sometimes even a gap of several months. We do not know if these gaps reflect intentional programming choices or unintentional lapses.

A number of factors, however, may have affected the accuracy of our estimate. First, as we have noted previously, MPS data sometimes contains errors or duplicates, meaning that some apparent “renewals” may in fact be the same filing, with, for example, one old entry and one newer, corrected entry. In addition, temporary activity location information has become less detailed over the past two years (now usually only listing the province of activity), meaning that activities may appear to have been in the same location (province), but could have in fact been carried out in different cities or counties. This would have caused us to overestimate the number of “renewals.” On the other hand, we may have underestimated by not recognizing “renewals” that were indeed the same activity but had changed in name only, or “renewals” that were the exact same project but filed with another CPU for practical reasons.

Using the criteria described above, we found around 90 activities that appear to be “renewals.” Below is a selected list of some of these activities: